MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
Respondent determined a $35,080 deficiency in petitioners' 1993 Federal income tax and a $2,490 addition to tax pursuant to section 6651(a)(1). The deficiency arises from respondent's reclassification of a $197,234 legal fee deduction petitioners claimed on Schedule C as a Schedule A deduction. As a consequence of this reclassification (1) the amount of the deduction was reduced because of the 2-percent...
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